OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

March 31, 1992

Dr. Richard F. Andree
Executive Vice President
Safety and Health Management Consultants, Inc.
161 William Street
New York, New York 10038

Dear Dr. Andree:

This is in response to your letter of December 11, 1991, addressed to former Assistant Secretary Gerard F. Scannell, in which you requested clarification concerning the coverage under 29 CFR 1910.1030 (Occupational Exposure to Bloodborne Pathogens) of employees who are assigned to perform first aid in non-health care industries. Please accept our apology for the delay in this response.

If an employee is trained in first aid and designated by the employer as responsible for rendering medical assistance as part of his/her job duties, that employee is covered by all requirements of the standard, including Hepatitis B vaccination, post exposure incident follow-up, training, and personal protective equipment.

We hope this information adequately addresses your concerns. Thank you for your interest in employee safety and health.


Dorothy L. Strunk,
Acting Assistant Secretary

December 11, 1991

Mr. Gerard F. Scannell
OSHA CCU # 9200349
Assistant Secretary
Occupational Safety & Health
US Department of Labor
Washington, DC 20210

Dear Mr. Scannell:

For non-healthcare industries such as manufacturing and construction who have employees assigned on an ad-hoc basis to perform first aid, what are the specific requirements an employer needs8 to accomplish to be in compliance with the Bloodborne Disease Standard?

Very truly yours,

Richard F. Andree, CSP, PE, Ph.D.
Executive Vice President